In re V.C.
66 A.3d 341
| Pa. Super. Ct. | 2013Background
- V.C., a fourteen-year-old, was adjudicated delinquent for robbery, theft by unlawful taking, receiving stolen property, and conspiracy regarding Shirley Phillips; and for second-degree murder, robbery, and conspiracy regarding George Greaves, with commitment to George Junior Republic for at least two years.
- A suppression motion sought to suppress his police statements following arrest for the Phillips robbery and Greaves murder; the motion was denied after a suppression hearing.
- Detectives testified that V.C. and his co-conspirator India Spellman participated in the Phillips robbery, and that V.C. later accompanied Spellman when they encountered Mr. Greaves and Spellman shot him.
- V.C. admitted to participating with Spellman in the Phillips robbery and to following Spellman afterward; he acknowledged that Spellman attempted to rob Mr. Greaves and that he aided or followed in preparatory acts leading to the murder.
- Detective Pitts testified V.C. waived Miranda rights after a short interview with his mother present; the juvenile court denied suppression and admitted the statements at the adjudication hearing.
- The juvenile court adjudicated V.C. delinquent for the Phillips offenses and for the Greaves offenses, and sentenced him to an intensive supervision program for a minimum of two years.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether there was sufficient evidence to prove conspiracy against Greaves. | V.C. was merely present and not part of a conspiracy. | Sufficient evidence showed a shared criminal intent and an overt act by Spellman and V.C. | Sufficient evidence to sustain conspiracy as to Greaves. |
| Whether V.C.'s confession was properly admitted after a Miranda waiver. | Waiver was voluntary, knowing, and intelligent given age and circumstances. | Waiver may have been tainted by age and parental issues, challenging voluntariness. | Confession was voluntary and properly admitted; suppression affirmed. |
Key Cases Cited
- In re A.V., 48 A.3d 1251 (Pa.Super.2012) (standard for sufficiency and evidence review in delinquency cases; supports appellate review of sufficiency by viewing record in light most favorable to Commonwealth)
- Commonwealth v. Knox, 50 A.3d 749 (Pa.Super.2012) (clarifies that conspiracy may be inferred from conduct and circumstances; presence alone is insufficient)
- Commonwealth v. Murphy, 795 A.2d 1025 (Pa.Super.2002) (conspiracy elements and use of circumstantial evidence analysis)
- Commonwealth v. Cousar, 593 Pa. 204, 928 A.2d 1025 (2007) (admissibility and sufficiency framework for delinquency/conspiracy)